PARKER WAICHMAN LLP

CONTINGENCY FEE RETAINER AGREEMENT

OUR PROMISE TO YOU: NO RECOVERY, YOU PAY NOTHING

THIS IS AN AGREEMENT BETWEEN Schrader, Angelmarie J. as the [PROPOSED] Administrator/ Executor of the Estate of John O. Jellison, hereafter referred to as Client, and PARKER WAICHMAN LLP, hereafter referred to as Law Firm. Unless a different Agreement is made in writing, this Agreement alone shall govern Law Firm’s and Client's respective rights and responsibilities. 1. Scope of Services:

(a) This Engagement

Client has agreed to retain the services of Law Firm in connection with Client’s claim for damages arising out of Client’s toxic exposure at Camp Lejeune. Law Firm will perform the following legal services, if necessary or appropriate, with respect to the claims described above:

investigation of claim(s);

determining responsible parties;

preparing and filing a lawsuit;

settlement procedures and negotiations;

prosecution of claim(s) by arbitration or legal action until settlement, award, or judgment is obtained; and

if judgment is obtained in Client's favor, opposing an opposing party's motion for new trial (if any).

(b) Law Firm is authorized to enter into negotiations regarding possible settlement, but will not settle or compromise this matter without the express written consent of Client.

(c) Services Not Included in This Engagement

This Agreement encompasses only services required for a single litigated trial, if necessary. Additional services that may be necessary or appropriate subsequent to a single litigated trial are not included within the scope of this Agreement. For example, such additional services may be required:

if the judgment obtained is not in Client's favor, or the amount thereof is unsatisfactory to Client;

if the judgment obtained is in Client's favor and an opposing party appeals from the judgment;

if a retrial is ordered after a motion for new trial or mistrial, or after reversal of the judgment on appeal; or

in judgment enforcement proceedings.

If additional legal services are necessary in connection with Client's claim(s), and Client requests Law Firm to perform such services, such additional services will only be performed pursuant to a separate written agreement between Client and Law Firm setting out such additional services and the additional fees payable in connection therewith. In the absence of such an agreement, and subject to Law Firm’s lien as set forth in paragraph 11 below, Client will have the right to engage other counsel to perform such additional services. Client understands that Law Firm is under no obligation to provide such additional services.

(d) Claims Excluded From This Engagement

Client(s) specifically authorizes, directs and instructs Law Firm(s) not to bring any claims for medical malpractice claims against any physicians, pharmacists, doctors, hospitals and/or any other health care providers. Client(s) also specifically authorizes, directs and instructs Law Firm(s) not to bring any claims for worker’s compensation benefits claims. Client(s) acknowledges that certain statutes of limitations may apply to claims which are not being brought and after the statute of limitations expires, those claims are forever barred. Law Firm(s) are not taking any position on the merits or availability of the claims which are not being brought and are not discouraging Client(s) from pursuing these claims. Client should seek other legal counsel immediately regarding this issue if Client(s) intends to pursue these types of claims. This Agreement does not cover any legal advice or other counseling with respect to the investment or other application of any monetary recovery, whether by way of settlement or judgment following a trial.

(e) No Guarantee as to Result

Client acknowledges that Law Firm has made no guarantees as to the outcome or the amounts recoverable in connection with Client's claim(s).

2. Statute of Limitations on Client’s Claims Against Defendants: Although Law Firm has agreed to represent Client in connection with Client’s claim(s), Client understands that there are strict statutes of limitations applicable to all legal claims, including claims arising out of toxic exposure at Camp Lejeune, and that if Client’s claims are not filed against Defendants before the statute of limitations expires, Client will be forever prevented from bringing a claim against Defendants. Client understands that Defendants may attempt to dismiss Client’s claims based upon those statutes of limitations. Client understands that the statutes of limitation in Client’s case may have expired before Client ever contacted Law Firm, or that the statute of limitations may expire in the very near future. Client agrees and understands that Law Firm will not be able to determine whether or not to file a lawsuit on Client’s behalf unless and until Client has provided (1) definitive proof of injuries related to toxic exposure at Camp Lejeune and (2) copies of Client’s medical records. Client also understands that it will take Law Firm a minimum of ninety (90) days after receipt of such information to evaluate Client’s case, and that should the statute of limitations or any other applicable deadlines including but not limited to claim registration deadlines, expire prior to or during the aforesaid ninety

(90) day period, client agrees not to hold Law Firm, or its associate counsel, responsible for any consequence related to the expiration of that deadline. Client understands and agrees that Law Firm is under no obligation to file a Complaint if Law Firm concludes, after reasonable investigation, that there is no legal basis for commencing an action.

3. Law Firm’s Right to Withdraw After Investigation: It is agreed that Law Firm is prosecuting Client’s claim(s) subject to its investigation of the facts and that if Law Firm determines in its sole judgment that Client’s claim(s) are being presented for any improper purpose; are not warranted by existing law or by a non-frivolous argument for the extension, modification, or reversal of existing law or the establishment of new law; do not have or are not likely to have evidentiary support; or it is not feasible to prosecute Client’s claim(s), Law Firm is permitted to cease all work on the Client’s claim(s) and is authorized to discontinue the prosecution of such claim(s), upon written notice to Client at Client’s last known address by regular mail. Law Firm’s right to withdraw will be subject to the ethical restrictions imposed upon Law Firm by the applicable Code of Professional Responsibility. In the event of such withdrawal by Law Firm, Law Firm shall promptly return Client’s file to Client and Client shall not be obligated to pay any Law Firm’s fee. Law Firm and Client agree that upon such withdrawal, Law Firm shall cease to be Client’s counsel, and Client will have the right to seek new counsel. The aforesaid right to withdraw is in addition to the Law Firm’s rights to withdraw as set forth in Paragraph 8(c) below. 4. Contingency Fee to Law Firms:

(a) Calculation of Contingency Fee: Client agrees to pay Law Firm forty percent (40%) of any recovery for all tort and related claims allowed by law that are not brought under the Federal Torts Claims Act, whether such recovery is by way of settlement, verdict, judgment, compromise or otherwise. However, for any claims brought under the Federal Torts Claims Act, Client agrees to pay Law Firm a contingency fee in accordance with 28 U.S. Code § 2678. Client agrees this arrangement is fair and reasonable. Unless a recovery is made, Client shall have no obligation to pay a fee to Law Firm. Under no circumstances will the contingent legal fees be greater than forty percent (40%) or as otherwise governed by applicable law.

(b) Costs and expenses as affecting contingency fee: Costs and expenses paid by Law Firm in connection with Client's claim shall be reimbursed after the contingency fee is computed. Client's share of the recovery shall be the balance remaining after reimbursement of such costs and expenses and payment of the contingency fee.

(c) Form of recovery as affecting contingency fee: If the recovery consists of payments to be made over a period of time, or other property not entirely cash or cash-equivalent, the contingency fee shall be based on the present cash value of the recovery as determined by generally-recognized accounting and appraisal standards. (For example, if the recovery consists of $1,000 payable at $100/per year over 10 years, its present value may be approximately $380, depending on prevailing interest rates.) The contingency fee shall be paid out of the first funds or property received by Client. Client understands that, because Law Firm’s fee shall be paid out of the first funds or property received, Client’s receipt of Client’s portion of any recovery may be delayed.

(d) Sanctions awards not part of recovery: Monetary sanctions awarded to Law Firm during the course of this litigation shall not be considered part of Client's recovery in this action. Such sanctions shall be deemed compensation to counsel for extraordinary time and effort expended as a result of an opposing party's bad faith conduct or failure to comply with discovery demands, court orders or similar obligations. But if the sanctions award includes a cost item (such as the filing fee for making a motion), the amount thereof shall be credited to Client's costs account when received by Law Firm.

(e) Court-awarded fee: Client agrees that in the event extraordinary services are required, Law Firm may apply to the Court for greater compensation. In the event that Law Firm is awarded a fee by a court that exceeds the percentages set forth above, the court-awarded fee shall apply in lieu of the above amounts.

(f) Discharge of Law Firm: If Law Firm is discharged, Law Firm will receive, at the election of Law Firm, either (1) the reasonable and fair value of the services provided by Law Firm prior to such discharge, as determined by the Court, provided that Client acknowledges that in connection with the determination of the fair and reasonable value of such services, the Law Firm’s normal hourly billing rates range from $450.00 to

$1,250.00 for attorneys and $150.00 to $225.00 for legal assistants and support staff, and Client agrees that such rates are fair and reasonable; or (2) a proportional share of the contingency fee portion of the ultimate recovery by the Client, such proportional share to be determined by comparing the amount or value of work done by Law Firm to the amount or value of work performed by other counsel, or as otherwise determined by the Court. If no election is made by the Law Firm at the time of discharge, Law Firm shall be presumed to have elected option

(2).

5. Litigation Costs and Expenses:

Law Firm is authorized to incur reasonable costs and expenses in performing legal services under this Agreement. Client agrees to pay for such costs and expenses in addition to the contingency fee discussed in paragraph 4, above.

(a) Advancement of costs: Law Firm may advance such costs and expenses on Client's behalf, the repayment of which, in accordance with applicable law, may be contingent on the outcome of the case.

(b) Particular costs and expenses: The costs and expenses necessary in this case may include any or all of the following items: court filing fees; process serving fees; witness fees; private investigator fees; photographer/graphic artist fees; fees to experts for consultation and/or appearance at deposition or trial; mail, messenger and other delivery charges; parking and other local travel; transportation, meals, lodging and all other costs of necessary out-of-town travel; long distance telephone charges; photocopying, imaging, and faxing charges; and computerized legal research charges. If it is deemed necessary by Law Firm to utilize a lien resolution service, this charge will be an expense against any settlement proceeds. This list is not exclusive. In addition to the foregoing expenses, other charges may be incurred in connection with the performance of the services described herein by Law Firm. Law Firm, with the approval of Client, may employ such technical experts or investigators who, in its opinion, are necessary to investigate the facts surrounding Client’s case or claim. All such experts shall report exclusively to Law Firm. It is agreed that Law Firm may decline, in its sole discretion, to advance such costs and disbursements for expert testimony, investigation or other services including trial and/or trial-related expenses.

(c) Medicare, Medicaid, and Private Health Insurance: We understand that current law and regulations regarding Medicare, Medicaid or private health insurance plans (Healthcare Providers) may require all parties involved in this matter (client, law firm, defendant, and any insurance companies) to compromise, settle, or execute a release of Healthcare Providers’ separate claim for reimbursement / lien for past and future payments prior to distributing any verdict or settlement proceeds. Client agrees that the Law Firm may take all steps in this matter deemed advisable for the handling of this claim, including hiring separate experts / case workers who assist with resolving any Healthcare Providers’ reimbursement claims or liens for past and/or future injury-related medical care. The expense of any such service shall be treated as a case expense and deducted from our net recovery and shall not be paid out of Law Firms’ contingent fee in this matter.

(d) Law Firm may incur expenses on behalf of multiple clients in connection with their individual matters (“Common Benefit Expenses”). For example, if a deposition of a defendant expert witness is taken in one case, and this deposition can be used for and/or benefit the claims of many other clients, the Firm classifies these costs as Common Benefit Expenses. Similarly, if the Law Firm spends $30,000 to hire an expert to reach an opinion on a topic affecting many clients, rather than charging the entire $30,000 to the first client who utilizes this expert, the Law Firm spreads the costs among all other clients in the group. Thus, if the Law Firms have 100 clients being represented in similar litigation, each client is charged $300 of the expert fee instead of the first client being charged $30,000. By using this Common Benefit Expenses system, no one client has to solely bear the costs that actually benefit the group as a whole, and many of the most substantial costs of litigation can be shared equally by all. Common Benefit Expenses include any and all costs that can benefit a group of clients. For example, to the extent charges benefit a group of clients, common benefits may include postage, faxes, telephone, copies, experts, investigation, computer research, transportation, and many of the costs incurred in actually trying one client’s case before a jury. Where a determination can be made of a specific allocation of such Common Benefit Expenses, Law Firm will apportion such expenses in accordance with such allocation among the respective clients. Where such an allocation cannot reasonably be made, Law Firm will divide Common Benefit Expenses equally among all the clients on whose behalf such expenses were incurred.

(e) Court-ordered assessments: If Client’s case is treated by a court as being substantially related to the claims of other claimants similarly situated, whether clients of the Law Firm or not, pre-trial proceedings relating to Client’s claims may be consolidated by the court with those of such other claimants. In that event, the court may direct that a portion of any recovery for Client’s claims (whether by verdict or settlement) shall be withheld for reimbursement of the costs and expenses involved with the coordination of the pretrial proceedings before the court. Should the court direct such withholding in connection with Client’s claims, Client and Law Firm agree that, in the absence of specific direction by the court, one half of such withheld amount shall be treated as expenses or costs incurred in connection with the prosecution of Client’s claim; the balance shall be deducted from the fee payable to the Law Firm in accordance with Section 4. 6. Waiver:

Law Firm may undertake representation of additional clients who also sustained personal injuries as a result of the conduct of the same defendant(s) and/or claims arising from toxic exposure at Camp Lejeune. This is not uncommon in this type of litigation. For example, cases involving personal injuries caused by Fen-Phen, Vioxx, Baycol, Accutane, Viagra, Zyprexa, Asbestos, Actos, Roundup Weed Killer, etc. involved attorneys representing numerous clients in each manner. Client understands that such multiple representations have advantages, but also may give rise to potential conflicts of interest since Law Firm must be concerned with the interests of more than one client simultaneously. Client is hereby advised of, and acknowledges, this potential conflict and the positive and negative aspects of multiple and collective representations. One of the advantages of multiple representations is that the disbursements/case expenses required to establish the general liability of the defendant(s), which constitute charges to be applied against the case at time of recovery by settlement or judgment, are spread across all of our cases on an equitable basis thus substantially reducing the costs to each individual client. Additionally, the relative bargaining position of an attorney who represents multiple clients during various negotiations with the defendant(s) is generally viewed as substantially superior to that of an attorney who represents a single or few clients. Furthermore, multiple representations afford the attorney the ability to expend more time and resources in litigating the issues in this case and in retaining top experts. A settlement with the defendant(s) may occur in many ways. It may be on a case-by-case basis, a settlement of the Law Firm’s entire inventory, a settlement of the entire inventory of the group of law firms with whom Law Firm has coordinated in the litigation (either informally or as a result of a court order), or any number of other possible methods. If a settlement is reached, each client’s recovery may depend on various factors such as age, severity and/or permanence of the injury, extent of past and/or future medical treatment, amount and duration of exposure, pre-existing health condition, etc. One process of evaluating settlement criteria and compensation amounts, in situations other than an individual case settlement, is referred to as a “matrix”. The

“matrix” may be formulated by the attorneys with the consultation of the Court, by experts, or by “Special Settlement Master(s)” appointed by the Court or who are agreed to by counsel for the various parties to the settlement. The “matrix” is based on criteria deemed relevant to evaluating claims within the litigation. Of course, each client always has the right to accept or reject the amount offered to them based on the “matrix” or otherwise. Occasionally, the defendant(s) will require acceptance of the settlement offer by a certain percentage of the law firms’/coordinated litigation group’s clients, reserving to the defendant(s) the right to withdraw the settlement offer if that certain percentage of acceptances is not obtained. Despite any potential conflicts, Client believes that the advantages of multiple representations outweigh any potential disadvantages and hereby waives any and all conflicts of interest that may arise from such multiple representations. Client acknowledges that Client has had the opportunity to discuss these issues with Law Firm and that this waiver is made after all questions have been fully answered.

7. Recovery:

In connection with any recovery on behalf of Client’s claim(s), Client expressly grants Law Firm authority to endorse and deposit into its Trust Account any checks in Client’s name, and authorizes Law Firm to deduct fees, costs, and expenses, and to pay the lien of any third party insurer, hospital, medical provider, or governmental entity related to the claim(s), from the Client’s share of the recovery. Any unpaid bills for medical care shall remain the Client’s obligation.

8. Assignment of Firm Personnel and Associate Counsel:

(a) Law Firm will designate a Contact Person who shall be primarily responsible for the supervision of Client’s matter, but Client is engaging Law Firm, not any attorney individually. As and when necessary, Law Firm will draw upon the talent and expertise of other partners and associates within the Firm and use paralegal staff to handle ministerial tasks.

(b) Client understands that Law Firm may associate with counsel from other Firms in connection with the prosecution of Client’s claim. Client agrees that the Law Firm’s fees set forth in paragraph 4 above will include fees due associate counsel, which fees shall be divided between Law Firm and associate counsel in compliance with the applicable provisions of the Code of Professional Responsibility. Client will pay no more in fees with the inclusion of associate counsel than Client would pay pursuant to this agreement if Law Firm solely represented Client. However, Client does agree to pay costs incurred by associate counsel on Client’s behalf in the same manner and to the same extent herein agreed as to Law Firm’s costs. Client agrees that Law Firm will not be financially responsible for any deliberate, willful and/or intentional misconduct of associate counsel, associate attorneys, and/or associate counsel employees, and in no event will Law Firm, and/or its employees be financially responsible for any punitive damages arising out of the conduct of associate counsel, associate counsel attorneys, and/or associate counsel employees, and/or anyone acting on the behalf of associate counsel.

9. Duties and Conduct:

(a) Law Firm’s Duties

(i) It shall be Law Firm’s duty to represent Client diligently in the course of its representation of Client in this matter.

(ii) Law Firm will keep Client informed of the status of this matter and consult with Client when appropriate. In the event that Client needs to reach Law Firm and the person sought is unavailable, Client should leave a message for the person concerned disclosing the nature and urgency of the call.

(b) Client’s Duties

In order for Law Firm to effectively advocate Client’s interests, it is important for Client to understand, and Client agrees that Client has an affirmative duty to assist and to cooperate with Law Firm as fully as possible during this engagement. Law Firm will rely on the completeness and accuracy of the information given to it by Client when performing services under this Agreement. In addition, Client will:

Promptly furnish Law Firm with information relative to the case history and financial and other aspects of the case, as well as other documents in Client’s possession or control when required;

Be fully candid and truthful regarding all information and documents provided to Law Firm;

Be available to work with Law Firm in preparation for depositions and court appearance and to discuss issues as they arise throughout this matter;

Promptly notify Law Firm in the event of a proposed settlement or offer to compromise; and

Not sign documents without prior review by Law Firm. Client(s) agrees and acknowledges that regardless of whether Client’(s) case is in active litigation at this time or not, it is Client’(s) duty to preserve evidence to Client’(s) case that will be potentially relevant or lead to other relevant evidence. Client(s) agrees and acknowledges that Client(s) will not remove, destroy, delete, modify, or in any way alter documents or electronically stored information relating to Client’(s) claim, injuries at issue in this litigation, and physical condition during the time Client(s) claims to have been suffering injuries caused by toxic exposure at Camp Lejeune. Client(s) agrees and acknowledges that Client(s) will not throw away any documents and other information Client(s) currently has in Client’(s) possession that are relevant to client’(s) claim, injuries, medical treatment, and/or damages. Client(s) understands and acknowledges that this duty to preserve evidence also applies to electronic information including anything stored on the Client’(s) Smart Phone or hard drive of Client’(s) computer, e-mails, computerized calendars, etc. as well as anything you may have posted to Facebook, Twitter, Instagram, or any other social networking site. Client(s) acknowledges that Client’(s) failure to comply with the warnings and directives herein may prejudice the Law Firm’(s) ability to properly litigate Client’(s) case and/or result in monetary sanctions and/or dismissal of Client’(s) case. Client(s) agrees and acknowledges that any postings to a blog or chat room and/or the information, particularly photographs, Client(s) posts to Facebook, Instagram, Snapchat, Twitter or any other social networking site will likely be subject to discovery and could negatively impact Client’s case. Client(s) agrees and acknowledges that Law Firm(s) has advised Client(s) that any case may suffer significant negative consequences as a result of postings on a social networking site. Client(s) agrees and acknowledges that Law Firm(s) has advised Client(s) that if Client(s) does post anything related to Client’(s) claims including photographs, Client(s) has an obligation to preserve that information. Client(s) acknowledges that Client’(s) failure to comply with the warnings and directives herein may prejudice the Law Firm’(s) ability to properly litigate Client’(s) case and/or result in monetary sanctions and/or dismissal of Client’(s) case.

(c) Law Firm’s Right to Withdraw

In addition to Law Firm’s right to withdraw as set forth in paragraph 3 above, Law Firm reserves the right to withdraw from the engagement and from the representation of Client, subject to the ethical restrictions imposed upon Law Firm by the applicable Code of Professional Responsibility, if Client fails to cooperate, including but not limited to failure to perform Client’s duties as described above, if Client misrepresents material facts, if Client fails to follow the advice of Law Firm (other than with respect to settlement, which is solely for the Client to decide), or if Client requests Law Firm to take any position or action that in Law Firm’s good faith opinion requires or permits our withdrawal because of professional duties imposed upon us by the applicable Code of Professional Responsibility. If Law Firm seeks to terminate this engagement for any reason, written notice will be given to Client.

10. Retention of File:

Client understands that Law Firm will only retain Client’s file for a period of seven years after the case is completed. After that seven-year period, the entire file will be discarded, and Law Firm will not retain a copy of any portion of the file. Consequently, it is Client’s responsibility to seek the return of all original documents, as well as any other portion of the file that Client wishes to retain, immediately after the case is completed. If Client waits beyond that seven-year period to make any such request, no portion of the file will be in existence at that time.

11. Discharge by Client:

Subject to Law Firm’s rights to a fee set forth in Section 4 above, and to assert a lien, as set forth in Section 12 below, Client shall have the right to discharge Law Firm at any time and for any reason upon written notice to Law Firm. If Client discharges Law Firm, Client understands that in consideration for the services Law Firm shall have provided up to the time of such discharge Law Firm will be entitled to be reimbursed for all costs and disbursements advanced by Law Firm on behalf of Client with respect to Client’s claim(s) immediately following such discharge, and to be paid a fee in accordance with Section 4(f). 12. Law Firm’s Lien:

To secure payment to Law Firm of all sums due under this Agreement for legal services rendered and/or costs advanced, Client hereby grants Law Firm a lien to the extent permitted by law on Client's claim(s) and any cause of action or lawsuit filed thereon, and on any recovery Client may obtain, whether by settlement, judgment, compromise or otherwise.

13. Binding Arbitration of Controversies, Disputes and/or Claims: All controversies, disputes and/or claims arising out of or relating to the representation of the client(s) arising out of or concerning this retainer, including all legal services rendered and/or to be rendered and/or authorized by this retainer and all causes of actions claimed by either party including but not limited to fee disputes, legal malpractice claims, claims of breach of fiduciary duty, breach of contract or any others claims and/or causes of action, shall be resolved exclusively through binding arbitration pursuant to the JAMS Comprehensive Arbitration Rules & Procedures in the State of New York administered by JAMS in accordance with its applicable rules and if the rules permit, judgment upon the award rendered by the arbitrator may be entered in any court having jurisdiction thereof. In any arbitration hereunder, to the extent permitted by the rules governing such arbitration, the arbitrators shall have the power, but not the obligation, to award all relief available in a court of law (excluding claims for punitive damages). You agree the prevailing party will be entitled to recover from the losing party all costs and expenses incurred in bringing and prosecuting or defending the arbitration, including reasonable attorneys’ fees and costs including the costs and expenses related to the attorneys of Parker Waichman prosecuting or defending the arbitration as well as the arbitrators' fees and costs. BY

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